Buying a US home through UK ltd company

Dual citizen (UK & US) currently living and working in UK via Ltd company.

Can I purchase residential property in the US through my current UK Ltd company which I plan to one day make my primary residence in the US?

If I one day leave the UK to permanently live in the US in this home would I need to pay UK tax on benefits in kind? I assume No since I would no longer be UK tax resident and will live & work in the US. What about in the US, is there a similar benefit in kind taxation?

Thanks

There are many tax consequences of buying the residential property via a company. These include-
•   SDLT will be paid on the purchase at the special rate for corporate purchasers of 15%.
•   There may be annual charges under the ATED rules.
•   There will be an annual benefit in kind charge.
•   The BIK will continue after non-residence, since it is a UK source benefit.
•   On the eventual sale, there will be no main residence relief. Instead the UK company will be taxed on any gain.’
•   The ownership by the company of the house may mean that any gain on the eventual winding up of the company does not attract Entrepreneurs Relief.

Would you be paying fair market rent for the occupation of the property?

Hello, thanks for the responses.

I was hoping that BIK would not arise in this situation, and no i was not intending to pay market rent but if that results in a BIK then there is no point.

Is there any other way this can be structured so that it doesn't require paying market rent and doesn't result in a BIK?  What if the UK entity owns a US company and that US company owns the property?

It sounds like your UK company is a controlled foreign corporation ("CFC").  The purchase of the U.S. real estate by the UK company will be an investment in U.S. property under section 956.  This means that you (as the shareholder of the CFC) will be taxed in the U.S. on the cost of the U.S. property.  It would be taxable as ordinary income and would not be treated as qualified dividend income.  Investments in U.S. property are very similar to subpart F income.

Has the entity made a valid check the box election?